On April 21, 2015, the Financial Crimes Enforcement Network of the U.S. Department of the Treasury (FinCEN), working in conjunction with U.S. Immigration and Customs Enforcement’s Homeland Security Investigations (HSI) and the South Florida Money Laundering Strike Force, released a rarely-issued Geographic Targeting Order (GTO) for certain areas of Miami-Dade County. The GTO requires certain businesses in the area covered by the GTO to take actions above and beyond those currently required under existing currency reporting law and regulations. The GTO becomes effective April 28, 2015, and, unless extended, expires Oct. 25, 2015. In this post, the authors discuss the restrictions imposed by the GTO as well as the requirements that need to be met for compliance sake.
